Comparison of ProTerra Standard V2.9 and the RTRS Standard for Responsible Soy Production Version 1.0 Prepared on behalf of: CERT ID LTDA 29th, August, 2011 Rua Dr Jorge Fayet, 55 Porto Alegre, RS - Brazil 2 Table of Contents: Introduction and Scope 3 1.1. Limitations 3 1.2. Report Structure 3 2.0. Key Aspect of the Standards 3 2.1. ProTerra Standard V2.9 3 2.2. RTRS Standard for Responsible Soy Production Version 1.0 4 3. Results of the Comparison Between Standards 5 Attachment 1 - Comparison Table 9 3 Introduction and Scope Argos Consultoria Ambiental LTDA (ARGOS) has been commissioned by CERT ID LTDA (CERT ID) to undertake a review of ProTerra Standard V2.9 (ProTerra) and the RTRS Standard for Responsible Soy Production Version 1.0 (RTRS), referred herein generically as standards. The main aim of the assessment is to provide and independent opinion on the differences and similarities of the standards with respect to its requirements and applicability. 1.1. Limitations This report is the result of the application of professional judgments. Professional judgments expressed herein are based on information publically available within the limits of the existing data, scope of work, budget and schedule and may result in subjective interpretation. The conclusions stated herein are intended as guidance and not necessarily as a firm course of action. ARGOS makes no warranties, expressed or implied, including, without limitation, warranties as to merchantability or fitness of a particular purpose of the standards object of this assessment. In addition, the information provided in this report is not to be construed as legal advice. ARGOS will accept no liability of whatsoever nature for claims from third parties. It was not part of this assessment the evaluation of the impact of the application of the standards to an organization in terms of implementation effort or certification costs nor the differences in approach or interpretation between the entities certifying on these standards with respect to, non-compliance, certification procedures, auditing and governance. 1.2. Report Structure The remainder of this document provides the following information: •• Section 2 provides a high level summary of the key aspects of each of the standards; •• Section 3 presents the results of the comparison between standards including discussion on their applicability; and •• Attachment 1 presents a detailed table with the requirements of the two standards, comparing each individual clause. 2.0. Key Aspect of the Standards The objective of this section is to provide a high level summary of the key aspects of each of the standards to enable the reader to understand the context and applicability of each one of them. Further discussion on the applicability of each of the standards can be found in section 3. 2.1. ProTerra Standard V2.9 ProTerra is a voluntary certification program for social responsibility and environmental sustainability developed by CERT ID. It is applicable to all 4 agricultural products and their derivatives, and is applicable worldwide. It also applies to transport, storage, and handling of agricultural products and to the processing of products into food, feed, and fiber components and manufacturing of foods, animal feeds, natural fibers, fuel and other non-foods for public consumption. The requirements to be met by the applicants are divided in two groups: Core Criteria that shall be met at certification and maintained throughout the certification period (one year) and Complementary Criteria. Complementary Criteria must be met according to an implementation plan agreed between applicant and certification entity. Its requirements are deployed from 18 principles as follows: •• PRINCIPLE 1: Compliance with laws, international accords and the ProTerra standard •• PRINCIPLE 2: Responsible personnel policies, labor practices •• PRINCIPLE 3: Responsible hiring, compensation and benefits practices •• PRINCIPLE 4: Protection of worker safety and health •• PRINCIPLE 5: Freedom for workers to organize and form associations •• PRINCIPLE 6: Effective communication with workers and community and grievance correction •• PRINCIPLE 7: Responsible impact on community •• PRINCIPLE 8: Legal and ethical land use •• PRINCIPLE 9: Effective environmental management •• PRINCIPLE 10: Effective management of biodiversity, non-crop vegetation, and environmental services •• PRINCIPLE 11: Genetically Modified Organisms (GMO) not used •• PRINCIPLE 12: Waste and pollution managed effectively •• PRINCIPLE 13: Water managed conservatively •• PRINCIPLE 14: Greenhouse gasses and energy managed effectively •• PRINCIPLE 15: Good agricultural practices adopted •• PRINCIPLE 16: Traceable and segregated chain of custody •• PRINCIPLE 17: Continuous improvement undertaken •• PRINCIPLE 18: Correct labeling and logo use 2.2. RTRS Standard for Responsible Soy Production Version 1.0 RTRS is a voluntary certification program developed by The Round Table on Responsible Soy Association. It is applicable to all kinds of soybeans, including conventionally grown, organic, and genetically modified. It has been designed to be used for all scales of soy production and all the countries where soy is produced. The requirements to be met by the applicants are not phased in time and where indicators require monitoring, a baseline is to be established at the time of 5 certification. Monitoring and review of trends or the results is done over time. Soy producers must commit to a process of continual improvement. Its requirements are deployed from 5 principles as follows: •• •• •• •• •• PRINCIPLE 1: Legal Compliance and Good Business Practice PRINCIPLE 2: Responsible Labor Conditions PRINCIPLE 3: Responsible Community Relations PRINCIPLE 4: Environmental Responsibility PRINCIPLE 5: Good Agricultural Practice 3. Results of the Comparison Between Standards The difference in the scope of each of the individual standards is a fundamental issue that should be kept in mind while reading the conclusions of this report. The standards are fit for different proposes and this explains and justifies the differences in the requirements between them. Both standards ultimately aim to accomplish the same objective: contributing to a more sustainable agriculture. At the level of the Principles all of the RTRS Principles find direct correlation with the ProTerra Principles. The opposite is not true since ProTerra has a more comprehensive and detailed set of Principles. As a general consequence the deployment of ProTerra Principles reflect in a greater number of requirement and indicators that cover a more extensive set of issues (several of which are not fully applicable to an organization dedicated exclusively to soy bean production). It can be generically stated that an organization certified under ProTerra scheme meets the requirements of RTRS. The contrary is not true. Total incompatibility between the standards is noted in the approach of following topics: use of genetically modified organisms and the approach to disruption of traditional land uses. There are also large differences in the approach with which the two standards deal with rainforest deforestation and conversion of high conservation value areas. For more details please refer to the discussion under items 2, 3 and 6 below. The key differences between the two standards are detailed below. 1) Difference in the scope of application. RTRS is applicable just to soybean production whereas as ProTerra is applicable to all agricultural products and their derivatives at every point in the food supply chain from farm to consumer’s plate. To the extent that an organization has a variety of agricultural related operations (from plantation to processing for example) or of crops, the ProTerra certification provides a single system capable of assessing and certifying the sustainability of all aspects of an agricultural and food production operation. 2) Genetically modified organisms. RTRS standard applies to both genetically modified and non- genetically modified production whereas under ProTerra genetically modified organisms (GMOs) must not be used. 6 3) Land use rights. Both standards have requirements addressing the legal and customary rights of traditional land users. ProTerra however considers that the conversion of land use that disrupts traditional uses is not allowed and that compensation measures are not sufficient, because such land conversion directly results in the loss of a way of life and typically fails to reach the actual affected parties. RTRS, in contrast, accepts compensation based on free, prior and informed and documented consent of traditional land users where rights have been relinquished. Furthermore RTRS allows certification even though there may be unresolved land disputes (“If there is litigation in process, while this is sub judice this will not prejudice access to certification provided that guidance provided by the judge is followed”). ProTerra requires land disputes to be resolved before certification can be awarded. 4) Products traceable and segregated. ProTerra has requirements and indicators to trace products back to the farm including record keeping requirements. No such provision exists under the RTRS production standard, although the RTRS chain of custody standard provides limited traceability and segregation. 5) Correct labeling and logo use. ProTerra has requirements and indicators linked to labeling of all retail and non-retail packaging allowing for traceability back through all links in the chain of custody. No such provision exits under RTRS, because RTRS is not a consumer-facing certification program. 6) Biodiversity. ProTerra has border requirements about protection of biodiversity including the implementation of a plan to maintain and maximize biodiversity within and surrounding the operation. RTRS limits the discussion of biodiversity within the farm area through the preservation of native vegetation. Furthermore ProTerra explicitly requires the need to compensate for land previously cleared of native vegetation between 1994 and 2004. Certified operations must implement compensatory measures to restore appropriate parts of the cleared areas to permanent preservation reserves. RTRS has a highly complex system for concluding that land is or is not to be protected or cleared. This system in many cases is dependent on the decision of an expert while ProTerra relies on much more clear cut criteria for determining whether or not a given piece of land is to be protected. 7) Water availability. Certified organizations under ProTerra may not undertake new initiatives that reduce the availability of water for neighboring communities, farms or for “traditional” uses. 8) Impact assessment. ProTerra requires a yearly assessment of impacts to the community and a general environmental impact assessment with an updated action plan. RTRS only requires assessing social and environmental impacts of large or high risk new infrastructure. 9) Legal compliance. ProTerra has clear requirements on the compliance with applicable international treaties and conventions whereas RTRS is silent on this topic. 10) Record keeping. ProTerra has a more detailed set of requirements for record keeping including records of: employee training, general personal/staff 7 information, legal compliance, health and safety performance, accident statistics for the operation, complaints and related responsive actions, agricultural production among others. 11) Social securities. Under ProTerra a social security plan shall be established for the workers in regions where such a plan is not required by law or regulation. RTRS has no similar provisions. 12) Health and safety. ProTerra explicitly requires for accident statistics and records of health and safety performance. RTRS has no similar provisions. Furthermore ProTerra requires a health and safety program and specifies compliance while RTRS requires awareness of health and safety matters and requires a safe and healthy workplace. Health and safety matters are not organized as programs in RTRS as they are under ProTerra and ProTerra is very specific with the handling of toxic substances leaving aside other risk situations (eg equipment/machinery handling). Finally RTRS requires system of sanctions for workers that do not apply safety requirements. 13) Communications with workers. ProTerra has specific requirements associated to communication with workers and the need to establish grievance correction (requirement that does not apply to individual small scale growers.). RTRS has no similar provisions. 14) Pesticide testing. ProTerra requires that organizations shall test agricultural produce on receipt for chemical residues (e.g., pesticides) and harmful contaminants (e.g., mycotoxins), and maintain testing records. RTRS has no similar provisions. 15) Good agricultural practice. ProTerra requires that water, soil, pests, fertility and irrigation are managed so as to avoid salinization and desertification of the soil. RTRS has no similar provisions. 16) Compliance of core suppliers and service providers. Suppliers of core inputs and services shall be compliant with the ProTerra Standard (as per definition a core supplier “is a supplier of a primary input to the production process. For instance, the supplier of soybeans is a core supplier to a soy crushing plant”). RTRS has no specific requirement for the compliance of supplier /service providers with its content. General guidance is however provided in a softer wording. 17) Community relations. RTRS requires collaboration in programs to train the local population while ProTerra requires broader participation of the certified organization in local development projects. 18) Waste and pollution management. ProTerra and RTRS are generally equivalent in the requirements however RTRS restricts the focus to crop residues, while ProTerra addresses all biological wastes. Furthermore RTRS allows use of burning as part of the land clearing and land conversion process, while ProTerra is stricter. 19) Green house gases. RTRS focuses on fossil fuel use, requiring monitoring, and allows increases in fossil fuel use with justification. In contrast, ProTerra 8 requires reductions over time in energy use and especially reduction of all forms of non-renewable energy, not just fossil fuels. A detailed comparison, requirement by requirement, can be found in Attachment 1. ProTerra has a total of 163 requirements and RTRS 126. All of the ProTerra requirements find equivalence or general equivalence (different level of details, guidance or requirements dealing with the same issue with minor difference in approach) to the RTRS requirements except one (RTRS 5.1.3 – “any direct evidence of localized contamination of ground or surface water is reported to, and monitored in collaboration with local authorities”). Thirty three (33) of ProTerra requirements find no direct correspondence in the RTRS Standard. 9 Attachment 1 - Comparison Table ProTerra V2.9 PRINCIPLE 1 - Compliance with law, international accords and the ProTerra Standard 1.1 Certified organizations shall comply with all applicable national and local laws, regulations, and applicable international conventions. RTRS V1 ProTerra Guidance RTRS Guidance Comments Principle 1: Legal Compliance and Good Business Practice 1.1 There is awareness of, and compliance with, CERT ID and its inspectors will avail all applicable local and national legislation. themselves of public records, both regarding local and national legislation and regarding case-specific matters relevant to the applicant operation. Requirement for legal compliance applies with regard to all Principles and their respective Criteria and Indicators. A list of relevant international accords is found in Appendix C. Producers need to have access to information which enables them to know what the law requires them to do. Examples include having a register of laws, or access to relevant advice on legislation. Legal compliance should be verified through: • checking publicly available data on compliance where available; • interviews with staff and stakeholders; and • field observations RTRS and ProTerra are generally equivalent, ProTerra however includes the requirement to comply with international accords or conventions, while no equivalent RTRS criteria exists. 1.1.1 Certified organizations shall implement procedures to assure consistent compliance. 1.1.2 Applicable laws are being complied with. RTRS and ProTerra are equivalent. 1.1.2 Certified organizations shall document and retain records of compliance for at least 5 years or longer if required by local law. 1.1.1 Awareness of responsibilities, according to applicable laws can be demonstrated. RTRS and ProTerra are generally equivalent, the latter being more specific. 1.1.3 Certified organizations and sub-contractors shall keep copies of up-to-date national and local legislation on site or demonstrate on-line access to these. No corresponding requirement exists in the RTRS Standard. However some level of guidance by RTRS is provided for RTRS 1.1. 1.1.4 If the ProTerra Standard exceeds national or local regulatory requirements, certified organizations shall adhere to the ProTerra requirement(s). No corresponding requirement exists in the RTRS Standard. 1.1.5 If the standards set in international treaties or conventions exceed local or national laws of the country where certification is sought, compliance with these standards will be achieved over time. No corresponding requirement exists in the RTRS Standard. 10 ProTerra V2.9 RTRS V1 1.2 Suppliers of core inputs and services shall be compliant with the ProTerra Standard. PRINCIPLE 2 - Responsible personnel policies, labor practices 2.1 Certified organizations shall not use slave labor, forced labor, indentured servants, and their equivalents. ProTerra Guidance RTRS Guidance For instance, for a soy processor’s output to be compliant with the ProTerra Standard, the soy, itself, must be produced in compliance with the ProTerra Standard. Compliance of the processing plant, alone, is not sufficient. Core and non-core suppliers/service Providers are defined in the Definitions section of the Standard. Comments No corresponding requirement exists in the RTRS Standard. Principle 2: Responsible Labor Conditions 2.1 Child labor, forced labor, discrimination and harassment are not engaged in or supported. This criterion applies to workers supplied by third parties and contracted labor, including migrant and seasonal workers. Note 1: The requirements of Principle 2 apply to both direct employees and to workers supplied by third parties. Note 2: The principle applies also to migrant, seasonal and other contract labor. In relation to compliance of these requirements by third parties (Note 1): Operations are expected to have a mechanism in place which enables them to adequately verify the compliance of their service providers. Auditors should evaluate the verification mechanism of the operations, to determine whether a sample of service providers should also be assessed by the auditors. Documented evidence of relevant personal data of workers should be verified (e.g. sex and date of birth). The data collected should be locally appropriate and legal (eg. it may not be appropriate or legal to ask for the religion of employees in some countries). (...) RTRS and ProTerra are equivalent. ProTerra does not mention child labor, discrimination or harrassment here, but covers these in clauses 2.2, 3.1, and 2.3, respectively. 11 ProTerra V2.9 RTRS V1 ProTerra Guidance RTRS Guidance Comments (...) 2.1.1-2.1.3 Personnel should be free to leave their work place after their hours of work have been completed, and be free to terminate their employment provided that they give reasonable notice. 2.1.1-2.1.3 Reference: ILO Convention 29 on Forced Labor and 105 on Abolition of Forced Labor. 2.1.1 No forced, compulsory, bonded, trafficked or otherwise involuntary labor is used at any stage of production. RTRS and ProTerra are equivalent. 2.1.1 No worker will be required to lodge their identity papers with their employer or any third party and workers pay, benefits or other property shall, likewise, not be retained. 2.1.2 No workers of any type are required to lodge their identity papers with anyone and no part of their salary, benefits or property is retained, by the owner or any 3rd party, unless permitted by law. RTRS and ProTerra are equivalent. 2.1.2 Accompanying family members (children and spouses) shall not be required to work on the farm. 2.1.3 Spouses and children of contracted workers are not obliged to work on the farm. RTRS and ProTerra are equivalent. 2.2 Child labor, except when permitted within national law, shall not be used in certified organizations. 2.1.4 Children and minors (below 18) do not conduct hazardous work or any work that jeopardizes their physical, mental or moral well being. 2.1.5 Children under 15 (or higher age as established in national law) do not carry out productive work. They may accompany their family to the field as long as they are not exposed to hazardous, unsafe or unhealthy situations and it does not interfere with their schooling. a. Minimum age for laborers shall be 15 years or the age mandated by Local Law, whichever is older. b. In family agriculture, child labor can be allowed provided that it is not abusive or dangerous, and does not interfere with the health, education and school attendance of the child. 2.1.4-2.1.5 Children and minors (below 18) do not work in dangerous locations, in unhealthy situations, at night, or with dangerous substances or equipment, nor do they carry heavy loads. They are not exposed to any form of abuse and there is no evidence of trafficked, bonded or forced labor. 2.1.4-2.1.5 Reference: ILO Convention 138 on Minimum Age and 182 on Worst Forms of Child Labor. RTRS and ProTerra are equivalent. ProTerra does not mention work conditions of the children/minors and their well being here, but covers these considerations in clause 4.2. RTRS and ProTerra are equivalent. ProTerra does not mention work conditions of the children/minors and their well being here, but covers these considerations in clause 4.2. 12 ProTerra V2.9 RTRS V1 ProTerra Guidance 2.3 Coercive disciplinary or control methods shall not be permitted. This includes corporal or mental coercion, confinement, threats of violence or other forms of physical, sexual, psychological, or verbal abuse/harassment. 2.1.8 Workers are not subject to corporal punishment, mental or physical oppression or coercion, verbal or physical abuse, sexual harassment or any other kind of intimidation 2.4 The work week shall be set according to local and national laws, shall be consistent with local industry standards, and shall, at maximum, not routinely exceed 48 hours per week (not including overtime). 2.5.3 Normal weekly working hours do not Agreements with Labor Unions take exceed 48 hours. Weekly overtime hours do precedence over the minimum wages not exceed 12 hours. determined by law. 2.5 Overtime shall be limited as specified in local and national law, and shall not routinely exceed 12 hours per week. 2.5.1 Overtime in excess of 12 hours is only allowable if it happens in extraordinary, limited periods where there are time constraints or risk of economic loss and where conditions regarding overtime in excess of 12 hours have been agreed between workers and management. 2.5.4 If additional overtime hours are necessary the following conditions are met: a) It only occurs for limited periods of time (eg. peak harvest, planting). b) Where there is a trade union or representative organization the overtime conditions are negotiated and agreed with that organization. c) Where there is no trade union or representative organization agreement the average working hours in the two-month period after the start of the exceptional period still do not exceed 60 hours per week. RTRS Guidance Comments RTRS and ProTerra are equivalent. 2.5 ‘Workers indirectly employed on the farm’ refers here to employees of service providers who carry out services directly related to the production process. The scope of ‘services directly related to the production process’ will be defined by national interpretations. RTRS and ProTerra are equivalent. RTRS and ProTerra are equivalent. 2.5.5 and 2.5.6 Reference: ILO Convention 1 The work time limits are flexible in that RTRS and ProTerra are on Hours of Work. they recognize that there may exist certain equivalent. unavoidable periods during the year, during which employees will be expected to work substantially longer hours for a restricted period do time. The extraordinary time pressure of harvest time is an example of such a situation. The requirement set down in 2.5.3 shall be respected during such periods. 13 ProTerra V2.9 RTRS V1 ProTerra Guidance 2.5.2 Overtime shall be compensated as required by law or according to agreement with the labor Union or, in the lack of those, at a premium rate. 2.5.6 Overtime work at all times is voluntary and paid according to legal or sector standards. In case overtime work is needed, workers receive timely notification. Workers are entitled to at least one day off following every six consecutive days of work. Legal dispositions which allow exchange of overtime hours for extra days off shall be taken into consideration. 2.5.3 All overtime work shall be voluntary. RTRS Guidance Comments 2.5.5 and 2.5.6 Reference: ILO Convention 1 RTRS and ProTerra are on Hours of Work. equivalent, except that ProTerra requires that a premium rate of compensation be paid for overtime. RTRS and ProTerra are equivalent. 2.5.4 In all cases workers are entitled to at least one day off following 6 consecutive days of work. RTRS and ProTerra are equivalent. 2.6 The certified organization shall structure, implement and document a personnel management program consistent with and proportional to the needs of the organization. No corresponding requirement exists in the RTRS Standard. 2.6.1 The certified operation shall assign a staff member to implement and manage the personnel management program. No corresponding requirement exists in the RTRS Standard. PRINCIPLE 3 - Responsible hiring, compensation and benefits practices 3.1 All workers, applicants and sub-contractors shall have equal employment opportunities and equal opportunities and treatment on the job. No discrimination shall be tolerated including: “any distinction, exclusion or preference made on the basis of race, color, sex, religion, political opinion, national extraction or social origin, which has the effect of nullifying or impairing equality of opportunity or treatment in employment or occupation, ... Any distinction, exclusion or preference in respect of a particular job based on the inherent requirements thereof shall not be deemed to be discrimination.” (Ref: ILO Convention 111, Articles 1 and 2). Principle 2: Responsible Labor Conditions 2.1.6 There is no engagement in, support for, or tolerance of any form of discrimination. There shall be no differences in the working conditions of any workers due to employment status (e.g., permanent, temporary or sub-contracted workers. However, “equal opportunities” and/or “equal treatment” shall not necessarily prevent certain workers from receiving rewards based on merit or performance, such as pay bonuses, paid vacation time, or other enhancements that are above and beyond the basic compensation due to all workers in the operation. 2.1.6-2.1.7 Discrimination includes, but is not limited to: any distinction, exclusion, restriction or preference based on race, color, social class, nationality, religion, disability, sex, sexual orientation, pregnancy, HIV status, union membership or political association, with the purpose or effect of annulling, affecting or prejudicing the recognition, fruition or equal exercise of rights or liberties at work, be it in the process of contracting, remuneration, access to training, promotion, lay-offs or retirement. Divergence in salary is not considered (...) RTRS and ProTerra are equivalent, except that the ProTerra requirement for establishing a social security plan for workers has no RTRS counterpart. 14 ProTerra V2.9 RTRS V1 ProTerra Guidance RTRS Guidance Comments (...) discriminatory when the company has a policy, which is fully known to the employees, which specifies different pay scales for different levels of qualifications, length of experience etc. 2.1.6-2.1.7 Reference: ILO convention 100 on Equal Remuneration, and ILO Convention 111 on Discrimination. 2.1.7 All workers receive equal remuneration for work of equal value, equal access to training and benefits and equal opportunities for promotion and for filling all available positions. 2.1.6-2.1.7 Discrimination includes, but is not limited to: any distinction, exclusion, restriction or preference based on race, color, social class, nationality, religion, disability, sex, sexual orientation, pregnancy, HIV status, union membership or political association, with the purpose or effect of annulling, affecting or prejudicing the recognition, fruition or equal exercise of rights or liberties at work, be it in the process of contracting, remuneration, access to training, promotion, lay-offs or retirement. Divergence in salary is not considered discriminatory when the company has a policy, which is fully known to the employees, which specifies different pay scales for different levels of qualifications, length of experience etc. 2.1.6-2.1.7 Reference: ILO convention 100 on Equal Remuneration, and ILO Convention 111 on Discrimination. Equivalent to ProTerra clause 3.1 15 ProTerra V2.9 3.2 All workers directly employed, contracted, subcontracted including temporary workers shall have an employment contract written in a language understandable by the worker and signed by the employer and employee or the employees’ labor representatives. RTRS V1 2.2.1 Workers (including temporary workers), sharecroppers, contractors and subcontractors have a written contract, in a language that they can understand. Clarity regarding the terms of work helps avoid conflicts between workers and management. Formalized contracts often serve to provide such clarity. The certification body acknowledges that in certain circumstances such contracts may not be practical or absolutely necessary. In absence of such contracts, employees or their representatives must declare to the certification body their satisfaction that the situation is acceptable without such contracts being in place. the certification body will evaluate all such scenarios on a case-by-case basis to determine if the objective of this section of the Standard is met. 2.2.2 Labor laws, union agreements or direct contracts of employment detailing payments and conditions of employment (e.g. working hours, deductions, overtime, sickness, holiday entitlement, maternity leave, reasons for dismissal, period of notice, etc.) are available in the languages understood by the workers or explained carefully to them by a manager or supervisor. 3.3 There shall be a signed work agreement between the certified organization and the sub-contractor. ProTerra Guidance Contracts typically include: pay rate, working hours, deductions, overtime conditions, vacation time, conditionns for sickness and maternity leave, grounds for dismissal, period of notice. RTRS Guidance 2.2 ‘Workers indirectly employed on the farm’ refers here to employees of service providers who carry out services directly related to the production process. The scope of ‘services directly related to the production process’ will be defined by national interpretations. In those countries where there are no requirements for formal labor agreements between worker and employer, alternative documented evidence of a labor relationship must be provided (eg. Registration of employees with social security / employment agency) Comments RTRS and ProTerra are equivalent. RTRS and ProTerra are generally equivalent. RTRS mentions details of the contract here, while ProTerra mentions these in clause 3.2 No equivalent requirement in RTRS. 16 ProTerra V2.9 3.4 Certified organizations shall communicate legal rights, contracts and agreements to their personnel in simple language and style that workers can easily understand and comply with. RTRS V1 2.2 Workers, directly and indirectly employed on the farm, and sharecroppers, are adequately informed and trained for their tasks and are aware of their rights and duties. 3.5 The certified organization shall maintain personnel records for each employee for at least 5 years or longer if required by local law. ProTerra Guidance RTRS Guidance The operation shall assign a person or persons to be responsible for maintaining and updating such information, and shall identify that person to CERT ID. RTRS and ProTerra are equivalent, except that training is not covered here, but in ProTerra clause 3.6.2. Personnel records will include for each employee their contract, their current status and history, job title, salary, training, hours worked, and vacation time accrued. No corresponding requirement exists in the RTRS Standard. 3.6 All employed and/or sub-contracted workers shall have the necessary qualifications, experience, meet legal requirements to fulfill their job. No corresponding requirement exists in the RTRS Standard. 3.6.1 Worker job descriptions, including necessary skills and legal status, and salary range shall be written and serve as the basis for the operation’s demonstration that this requirement is being met. 3.6.2 An ongoing program of training shall be provided to all workers to ensure that they are competent to conduct their work efficiently, effectively and safely. Comments No corresponding requirement exists in the RTRS Standard. This is an important requirement because it provides the auditor information necessary to assure fair and equal wages are being paid for each job. 2.2 Workers, directly and indirectly employed on the farm, and sharecroppers, are adequately informed and trained for their tasks and are aware of their rights and duties. If this criterion is first being met during the initial year that ProTerra certification is achieved, the certification body will waive the retroactive aspect of it for the first year of certification. ‘Workers indirectly employed on the farm’ refers here to employees of service providers who carry out services directly related to the production process. The scope of ‘services directly related to the production process’ will be defined by national interpretations. In those countries where there are no requirements for formal labor agreements between worker and employer, alternative documented evidence of a labor relationship must be provided (eg. Registration of employees with social security / employment agency) Equivalent for ProTerra and RTRS. Education on workers' rights is covered in ProTerra in clause 3.4. 17 ProTerra V2.9 RTRS V1 3.6.3 Certified organizations shall maintain records for all training for a minimum of 5 years, or longer if specified by local regulations. 3.7 All workers, regardless of age or gender, shall be paid a fair, locally representative wage or salary, which shall meet or exceed the Minimum or Basic Salary or Wage (Minimum Wage) legally established for the region. If no Minimum Wage law exists, compensation shall at least meet the typical salaries usually paid in that region for the equivalent function or job. ProTerra Guidance The following information shall be included in these records: date, time, attendees, trainer, and content material used during training. 2.5 Remuneration at least equal to national legislation and sector agreements is received by all workers directly or indirectly employed on the farm. 3.8 Piece work shall be paid at a rate that assures workers (female and male) will be capable of earning at least a legal minimum wage. 2.5.8 If workers are paid per result, a normal 8 hour working day allows workers, (men and women), to earn at least the national or sector established minimum wage. 3.9 Wages or salaries and hours worked shall be regularly and legally paid in the national currency, documented and recorded. 2.5.2 Deductions from wages for disciplinary purposes are not made, unless legally permitted. Wages and benefits are detailed and clear to workers, and workers are paid in a manner Convenient to them. Wages paid are recorded by the employer. The operation must demonstrate to the certification body and its inspectors how it arrived at its determination that it has met this requirement. Payment shall be at least monthly unless workers or their representatives expressly agree that it can be less frequent, the terms of which are specified in writing and signed by said parties. No corresponding requirement exists in the RTRS Standard. ‘Workers indirectly employed on the RTRS and ProTerra are farm’ refers here to employees of service generally equivalent, the providers who carry out services directly latter being more specific. related to the production process. The scope of ‘services directly related to the production process’ will be defined by national interpretations. 2.5.5 and 2.5.6 Reference: ILO Convention 1 on Hours of Work. RTRS and ProTerra are equivalent. Equivalent to ProTerra 3.9. Deductions for social security or other legally mandated programs are acceptable. 2.5.1 Gross wages that comply with national legislation and sector agreements are paid at least monthly to workers Comments RTRS and ProTerra are equivalent. 2.5.5 Working hours per worker are recorded by the employer. 3.10 Employer shall not deduct from wages for disciplinary or similar purposes. RTRS Guidance RTRS and ProTerra are equivalent. Equivalent to ProTerra 3.9 criterion and guidance. 18 ProTerra V2.9 RTRS V1 3.11 A social security plan shall be established for the workers in regions where such a plan is not required by law or regulation. ProTerra Guidance RTRS Guidance The plan shall include timelines for implementation, as well as age requirements for receiving benefits and other related conditions/situations where benefits would be available. The impact of such a social security plan on regular worker pay amounts shall be specified in the plan description. No corresponding requirement exists in the RTRS Standard. 3.12 All workers, regardless of age or gender, shall enjoy appropriate, legally compliant working conditions. 3.13 All workers living on site shall have appropriate, fairly priced, and safe food, water and housing. PRINCIPLE 4 - Safety and health of workers protected 4.1 The organizations shall have a worker health and safety program that at minimum assures compliance with legal requirements or with requirements of the Standard as set out below, which ever is more protective. Comments No directly correspondent clause in RTRS, but general requirement for compliance to the law has applicability here. 2.5.9 If employees live on the farm, they have access to affordable and adequate housing, food and potable water. If charges are made for these, such charges are in accordance with market conditions. The living quarters are safe and have at least basic sanitation. “Appropriate” includes at least the following: shelter from the elements; exclusion of pests; ready access to facilities for maintaining hygiene; ready access to water, facilities for food preparation and eating; clean sleeping and sitting quarters (including some type of bed), and open space where workers would be able to move around freely during non-working hours. RTRS and ProTerra are equivalent. However ProTerra provides more detailed guidance Principle 2: Responsible Labor Conditions 2.3 A safe and healthy workplace is provided for all workers. 2.3.1 Producers and their employees demonstrate an awareness and understanding of health and safety matters. Scope and complexity of the program shall be proportional to the scope and complexity of the certified organization. 2.3 References: ILO convention 155 on Occupational Safety and Health; ILO Convention 184 on Safety and Health in Agriculture; ILO Recommendation 192 on Safety and Health in Agriculture. The means of verification used should be appropriate to the size and scale of the operation. E.g. (2.3.1) For operations with permanent employees there should be a documented health and safety policy. For small farms this can be demonstrated through verbal explanations. General equivalence between ProTerra and RTRS, but with different emphasis. ProTerra requires a health and safety program and specifies compliance while RTRS requires awareness of health and safety matters and requires a safe and healthy workplace. Health and safety matters are not organized as programs in RTRS 19 ProTerra V2.9 4.1.1 The certified organization shall conduct a risk assessment of their operation and use the results of that study to guide mitigation of risks and development and implementation of accident and emergency systems and procedures. RTRS V1 ProTerra Guidance RTRS Guidance Comments 2.3.2 Relevant health and safety risks are identified, procedures are developed to address these risks by employers, and these are monitored. RTRS and ProTerra are equivalent. 2.3.6 Accident and emergency procedures exist and instructions are clearly understood by all workers. Equivalent to ProTerra 4.1.1 4.1.2 Medical treatment/first aid shall be readily and quickly available if and when accidents or other emergencies occur on the worksite. 2.3.7 In case of accidents or illness, access to first aid and medical assistance is provided without delay. RTRS and ProTerra are equivalent. 4.1.3 The certified organization shall monitor and ensure compliance with its worker safety and health program and keep records of health and safety performance, including accident statistics for the operation. 2.3.2 Relevant health and safety risks are Accident statistics: accidents per hours identified, procedures are developed to worked and accidents per employee. address these risks by employers, and these are monitored. Generally equivalent however ProTerra explicitly requires the keeping of accidents statistics and records of health and safety performance. 2.3.3 Potentially hazardous tasks are only carried The operation shall maintain out by capable and competent people who documentation identifying employees do not face specific health risks. excluded from these activities and require sub-contractors to do the same. The certification body may allow for the minimum/maximum ages to be lower/ higher than 18/60 in cases where national legislation and/or other legal permitting procedures are in effect, and provided there are measures in place to adequately protect the health and safety of such workers. RTRS and ProTerra are generally equivalent, the latter being more specific in identifying specific classes of vulnerable workers who must be protected. 4.2 Conduct of hazardous tasks, including the application or handling of pesticides (insecticides, fungicides, and herbicides) for pests, diseases and non-crop plants, shall be carried out by qualified and properly trained workers, and shall not be permitted by the following types of employees, including sub-contracted workers: Persons under the age of 18 or above the age of 60 - Pregnant or nursing women - Persons with mental illness - Persons with chronic, hepatic, renal, or respiratory diseases Persons with other health problems or limitations that would make them more vulnerable to hazardous conditions 20 ProTerra V2.9 RTRS V1 4.2.1 Certified organizations shall provide all required personal protection equipment (PPE) and clothing. 2.3.4 Adequate and appropriate protective equipment and clothing is provided and used in all potentially hazardous operations such as pesticide handling and application and mechanized or manual operations. 4.2.2 Wearing of appropriate personal protection equipment (PPE) and clothing is mandatory during handling and application of toxic substances or conduct of other hazardous tasks. 2.3.5 There is a system of warnings followed by legally-permitted sanctions for workers that do not apply safety requirements. 4.3 Workers shall be trained in health and safety on the job, and particularly those workers handling pesticides and other toxic substances or hazardous equipment shall be trained to store, apply, and dispose of pesticides and other toxic substances and to operate hazardous edquipment safely, as specified in the manufacturer’s instructions and legal requirements. 2.2.3 Adequate and appropriate training and comprehensible instructions on fundamental rights at work, health and safety and any necessary guidance or supervision are provided to all workers. ProTerra Guidance RTRS Guidance Comments RTRS and ProTerra are generally equivalent. RTRS however requires system of sanctions for workers that do not apply safety requirements In addition to conducting all aspects of their work safely, all pesticide use and disposal shall be handled in a manner that protects the worker and others in the vicinity as well as the environment. Examples of additional measures that may be taken is the marking of areas where pesticides are stored, handled, or used. RTRS and ProTerra are generally equivalent. However ProTerra is very specific with the handling of toxic substances leaving aside other risk situations (eg equipment/machinery handling). 4.3.1 Certified organizations shall maintain records for all health and safety training for a minimum of 5 years, or longer if specified by local regulations. The following information shall be included in these records: date, time, attendees, trainer, and content material used during training. No corresponding requirement exists in the RTRS Standard. 4.3.2 Certified organizations shall employ qualified personnel to instruct workers in safety and health on the job, and especially in the safe handling, storage, and application of pesticides and other toxic materials and the safe conduct of other hazardous tasks. Certified organizations shall ensure that instructors have necessary technical knowledge and legal qualifications. No corresponding requirement exists in the RTRS Standard. 21 ProTerra V2.9 4.4 Certified organizations will, at least, comply with regulations regarding maternity leave. 4.4.1 Workers taking maternity leave have the right to resume their work under the same conditions existing before taking leave, without discrimination, deduction of wages or loss of seniority. RTRS V1 ProTerra Guidance 2.5.7 Salaried workers have all entitlements and protection in national law and practice with respect to maternity. Workers taking maternity leave are entitled to return to their employment on the same terms and conditions that applied to them prior to taking leave and they are not subject to any discrimination, loss of seniority or deductions of wages. RTRS Guidance 2.5 ‘Workers indirectly employed on the farm’ refers here to employees of service providers who carry out services directly related to the production process. The scope of ‘services directly related to the production process’ will be defined by national interpretations. 4.4.2 In locations where specific regulations do not cover the topics, reasonable maternity leave, and leave for health treatment shall be established. PRINCIPLE 5 - Freedom for workers to organize and form associations 5.1 All workers and share-croppers shall be allowed to form and join trade unions or other collective bargaining organizations. Comments RTRS and ProTerra are generally equivalent. No corresponding requirement exists in the RTRS Standard. Principle 2: Responsible Labor Conditions 2.4 There is freedom of association and the right to collective bargaining for all workers. 2.4.1 There is the right for all workers and sharecroppers to establish and/or join an organization of their choice. 2.4.3 All workers have the right to perform collective bargaining. Evidence must be provided demonstrating that the certified organization respects the rights of all personnel to form and join trade unions or other collective bargaining organizations in accordance with the law. Not applicable to small-holder/family farmers. RTRS and ProTerra are generally equivalent. 2.4.1 Reference: ILO Convention 87 on Freedom of Association and Protection of the Right to Organize. 2.4.3 Reference: ILO Convention 98 on Right to Organize and Collective Bargaining. 22 ProTerra V2.9 5.1.1 Certified organizations shall inform all workers of their rights of association and of negotiation. RTRS V1 Workers, directly and indirectly employed on the farm, and sharecroppers, are adequately informed and trained for their tasks and are aware of their rights and duties. ProTerra Guidance RTRS Guidance These shall be posted in written form where they can be readily read by all employees in a language/terminology that workers can readily understand. ‘Workers indirectly employed on the farm’ refers here to employees of service providers who carry out services directly related to the production process. The scope of ‘services directly related to the production process’ will be defined by national interpretations. In those countries where there are no requirements for formal labor agreements between worker and employer, alternative documented evidence of a labor relationship must be provided (eg. Registration of employees with social security / employment agency) Comments RTRS and ProTerra are equivalent. 5.1.2 Functions of collective bargaining organizations shall not be impeded by certified organizations. 2.4.2 The effective functioning of such organizations is not impeded. Representatives are not subject to discrimination and have access to their members in the workplace on request. RTRS and ProTerra are equivalent. 5.1.3 Representatives of collective bargaining organizations shall have access to their members at the workplace. 2.4.4 Workers are not hindered from interacting with external parties outside working hours (e.g. NGOs, trade unions, labor inspectors, agricultural extension workers, certification bodies). RTRS and ProTerra are generally equivalent. ProTerra requires that the certified organization allow collective bargaining organizations access to workers on the worksite, while RTRS does not require this but only requires the certified organization to allow access outside of working hours. Although RTRS 2.4.4 requires access on request. 2.4.2 The effective functioning of such organizations is not impeded. Representatives are not subject to discrimination and have access to their members in the workplace on request. RTRS and ProTerra are equivalent. 5.1.4 Workers shall not be penalized for interacting with union representatives or other organizations. 5.1.5 There shall be no discrimination by management or workers between unrepresented workers and members of labor or trade unions. ProTerra V2.9 PRICIPLE 6 - Effective communication with workers and community and grievance correction 6.1 Certified organizations shall establish and document an effective and timely system of communication with all workers and with the local communities, traditional land users and other concerned or affected parties and an effective and timely system to receive, investigate and respond to all complaints from these parties. RTRS V1 ProTerra Guidance RTRS Guidance Comments This requirement does not apply to individual small scale growers. This system shall function at the worksites and in the communities linked to certified organizations. Communication channels need to use local languages and appropriate mediums (eg. the internet is not an appropriate mechanism for communication with communities that have no access to the internet). The communication requirements must be adequate to identify any disputes with traditional land users as referred to in Criterion 3.2 Where people on or adjacent to the property are demonstrated to be illegal (for example illegal squatters), producers should try to engage in communication, but they are not obliged to maintain a dialogue. Local communities may be represented by legitimate representatives in communication or negotiation or in audit situations. Where this is the case, this does not exempt the producer or the auditor from the responsibility of communicating with other members of the community, especially groups such as the poor, illiterate, youth, women or indigenous groups. In the case of small farms documented evidence is not required and is substituted by verbal evidence. It is important to include interviews with members of the community to evaluate the existence of the communication channels and their appropriateness. ProTerra requires an effective communication and grievance resolution system with respect to both workers and the community, while the RTRS requirement applies only to the community and not to workers. With respect to the community, RTRS and ProTerra requirements are equivalent, although RTRS provides more detail. (...) Principle 3: Responsible Community Relations 3.1 Channels are available for communication and dialogue with the local community on topics related to the activities of the soy farming operation and its impacts. 3.1.2 The channels adequately enable communication between the producer and the community. 3.1.3 The communication channels have been made known to the local communities. 23 24 ProTerra V2.9 RTRS V1 ProTerra Guidance 3.3 A mechanism for resolving complaints and grievances is implemented and available to local communities and traditional land users. RTRS Guidance Comments Note: For group certification - the (...) complaints and grievances mechanism can be managed by the group manager and records of complaints and grievances can be maintained at the group level. Interviews with members of local communities and their representatives are important in verifying compliance with this criterion. 3.3.1 The complaints and grievances mechanism has been made known and is accessible to the communities. 3.3.2 Documented evidence of complaints and grievances received is maintained. 3.3.3 Any complaints and grievances received are dealt with in a timely manner. 6.1.1 Complaints, responsive actions, and outcomes shall be documented and records maintained for 5 years or more if required by local law. 6.1.2 The system shall include a mechanism that allows workers and community members to lodge complaints in a manner anonymous to the management of the certified organization (if anonymity is desired), yet also allows verification of the validity of the complaints. 3.1.1 Documented evidence of communication channels and dialogue is available. Auditor will look into the number of complaint resolution processes and verify the number of effective resolutions achieved. RTRS and ProTerra are generally equivalent. One example of such a system would be to appoint an independent ombudsman who receives complaints, assesses validity and sets in motion appropriate processes for correction/redress. The procedures for electing/appointing the ombudsman must be transparent and must equitably include workers, community members or their representatives in the appointment process. No corresponding requirement exists in the RTRS Standard. 25 ProTerra V2.9 PRINCIPLE 7 - Responsible impact on community RTRS V1 ProTerra Guidance RTRS Guidance Comments Principle 3: Responsible Community Relations 7.1 Certified organizations (Levels I, II and III) shall conduct and document an assessment of their impact on the local community and, if present, indigenous people. This shall be updated yearly. The requirements in this section do not apply to small scale individual growers, but do apply to their organizations, such as cooperatives. No corresponding requirement exists in the RTRS Standard. 7.2 The results shall be incorporated in planning activities and operational procedures. No corresponding requirement exists in the RTRS Standard. 7.3 Certified organizations shall demonstrate support for local community development projects. 3.4.2 There is collaboration with training programs for the local population. RTRS requires collaboration in programs to train the local polulation while ProTerra requires broader participation of the certified organization in local development projects. 7.4 Certified organizations shall contribute to the local economy by preferentially offering local businesses the opportunity to supply goods and services that meet the organizations’ specifications. 3.4.3 Opportunities for supply of goods and services are offered to the local population. RTRS and ProTerra are equivalent. 3.4 Fair opportunities for employment and provision of goods and services are given to the local population. RTRS and ProTerra are equivalent. 7.5 Job opportunities shall be made available first to qualified members of the local community. 3.4.1 Employment opportunities are made known locally. Note: Not applicable for small farms. 3.4.1 Evidence may include records kept of the proportion of local employees 26 ProTerra V2.9 PRINCIPLE 8 - Land use legal and ethical 8.1 Land used by the certified organization does not impair the legal or customary rights of other users, including indigenous communities. 8.1.1 The certified organization shall provide documented evidence that their land use does not impair customary rights of other users. RTRS V1 ProTerra Guidance RTRS Guidance Comments Land use conversion that disrupts traditional land use is not allowed under the ProTerra Standard. Therefore there is no need for ProTerra to contain a requirement for "prior informed consent" of indigenous peoples or small holders and no need for a rerquirement for compensate for disruption of traditional land use because disruption of traditional land use is simply forbidden in ProTerra. It is the observation that when traditional land use is disrupted, effforts to compensate for this disruption frequently fail to reach the actual affected parties, and is consistently insufficient to justly compensate for such disruption, which, in essence, represents the loss of a way of life. When applying for certification the producer will identify traditional land users. Traditional land users will provide reasonable proof that they have been exercising use or access rights on the area of the property over the 10 years prior to May 2009 (the ‘cut-off date’) . In the case of traditional indigenous communities, articles 14-18 of ILO convention 169 also apply. Traditional land users may be represented by legitimate representatives in communication, negotiation or audit situations. Where this is the case, this does not exempt the producer or the auditor from the responsibility of communicating with other members of the community. Not equivalent. Both standards have requirements addressing the legal and customary rights of traditional land users but adopt totally different approaches. Therefore on the basis of the different approaches there is no equivalence between the requirements. RTRS allows disruption of traditional land use as long as someone is paid money as compensation, while ProTerra forbids all traditional land use disruption (see ProTerra guidance for additional commentary on the implications of this). In addition, it should be noted that RTRS does not require resolution of land disputes before certification is granted to the operator, while ProTerra does. Principle 1: Legal Compliance and Good Business Practice Principle 3: Responsible Community Relations 3.2 In areas with traditional land users, conflicting land uses are avoided or resolved. 3.2.2 Where rights have been relinquished by traditional land users there is documented evidence that the affected communities are compensated subject to their free, prior, informed and documented consent. 27 ProTerra V2.9 RTRS V1 8.1.2 Land use in all cases shall not interfere with the agricultural production systems of neighbors, so as to allow coexistences of different production systems. 5.10 Appropriate measures are implemented to allow for coexistence of different production systems. 8.2 Land use by the certified organization is legal, either through ownership, lease, or other appropriate agreement. ProTerra Guidance RTRS Guidance Comments 5.10.1 Measures are taken to prevent interference in production systems of neighboring areas. 1.2 Legal use rights to the land are clearly defined and demonstrable. Note: Land use rights of traditional land users are considered in Criterion 3.2 which should be cross-referenced with this criterion. 1.2.1 There is documented evidence of rights to use the land (e.g. ownership document, rental agreement, court order etc.). 8.2.1 The certified organization shall provide evidence that land use is legal in the form of ownership deed, lease, or other appropriate legal agreement. 8.2.2 Land rights disputes shall be resolved before certified status can be awarded. 3.2 In areas with traditional land users, conflicting land uses are avoided or resolved. 3.2.1 In the case of disputed use rights, a comprehensive, participatory and documented community rights assessment is carried out. 4.4.2 There is no conversion of land where there is an unresolved land use claim by traditional land users under litigation, without the agreement of both parties. RTRS allows certification even though there may be unresolved land disputes. ProTerra requires land disputes to be resolved before certification can be awarded. RTRS disallows certification of disputed land only if there is active litegation. Since displaced indigenous people and small-holders are often not able to mount formal legal action, the requirement for formal legal action creates a very large loophole that favors those who want to convert lands. 28 ProTerra V2.9 PRINCIPLE 9 - Effective environmental management program 9.1 Certified organizations shall perform a comprehensive social and environmental impact assessment (SEIA) to identify potentially harmful or damaging impacts of the operation and to define an action plan to address these impacts. RTRS V1 ProTerra Guidance RTRS Guidance Comments Principle 4: Environmental Responsibility 4.1 On and off site social and environmental impacts of large or high risk new infrastructure have been assessed and appropriate measures taken to minimize and mitigate any negative impacts. This plan will take into account the sustainability of the environment, wildlife and endangered species, impact on the local population and indigenous people. Note: For group certification – this also applies to large new infrastructure projects developed by the entity holding the group certificate, where the infrastructure is used by certified group members or the certified If the organization does not have expertise soy they produce. The assessment should in house to effectively conduct the SEIA, be appropriate to the scale of the operation guidance from government, academic or and the new infrastructure. Where there are other recognized experts shall be accessed. existing national requirements for impact assessments which are adequate to meet As part of their Action Plan, Certified this criterion (identified by the NTG) these organizations shall develop and implement are followed. Where not, the auditors must initiatives to maintain and increase verify that an adequate process has been biodiversity around their facilities. followed. Where no adequate legislation Examples of such initiatives include the exists and national interpretation is not following: available, the Equator Principles’ Social a. Creation and maintenance of vegetation and Environmental assessment procedure corridors to link areas of natural vegetation. should be followed. b. Conversion of unproductive areas into conservation areas. Plots that have been farmed with practices that have led to low- or non-productivity may be reclaimed as farmland provided they are stewarded in a manner that recreates fertility and restores biodiversity. The SEIA will make use of the communication and grievance rectification mechanisms described under Principle 6 to assure that the SEIA process is known to all relevant parties and these are engaged in a transparent and effective manner that assures negative impacts of the operation are minimized and mitigated and positive maximized. Not equivalent. RTRS only requires a social and environmental assessment prior to the establishment of a large or high risk new infrastructure (4.1.1 - 4.1.4). ProTerra requires a social and environmental assessment of the whole operation. (...) 29 ProTerra V2.9 RTRS V1 ProTerra Guidance RTRS Guidance 4.1.1 A social and environmental assessment is carried out prior to the establishment of large or high risk new infrastructure. Comments (...) 4.1.2 The assessment is carried out by someone who is adequately trained and experienced for this task. 4.1.3 The assessment is carried out in a comprehensive and transparent manner. 9.2 Certified organizations shall carry out the action plan specified in 9.1 and will review and revise it annually prior to the ProTerra inspection, including consideration of new projects, assessing progress, revising and setting new objectives, as appropriate. PRINCIPLE 10 - Effective management of biodiversity, non-crop vegetation, and environmental services 10.1 Areas of native vegetation and other high conservation value areas, cleared after 2004 cannot not be converted into agricultural areas or used for industrial or other commercial purposes, in particular the following: · Primary Forests (i.e. rainforests) · Riparian Vegetation · Wetlands · Swamps · Floodplains · Steep slopes · Other high conservation value areas 10.1.1 Certified organizations shall adhere to governmental regulations and international (...) 4.1.4 Measures to minimize or mitigate the impacts identified by the assessment are documented and are being implemented. ProTerra will audit annually the progress and implementation of the environmental action plan. This plan is expected to become more concrete and comprehensive over time. RTRS and ProTerra are generally comparable. An example of a prohibited industrial use of resources would be timber cut for the purposes of drying grain. RTRS is significantly less stringent regarding this principle. 1. RTRS has a cutoff of 2009 for clearling of native forest, while ProTerra’s general cutoff is 1994 but accepts land that has been cleared up to 2004, if compensatory environmental measurees have been taken. 2. Whereas ProTerra forbids land conversion in the Amazon biome and uses a strict GPS based approach to defining the Amazon biome, the RTRS uses a more subjective system (...) Principle 4: Environmental Responsibility 4.4 Expansion of soy cultivation is responsible. 4.4.1 After May 2009 expansion for soy cultivation has not taken place on land (...) Note: This criterion will be revised after June 2012 if RTRS-approved maps and system are not available. 4.4.1.2 c) Options 1 and 2 only apply for For certification decisions, the areas which are not native forest (as stated Amazon biome is defined according to in 4.4.1.2 b and c). Therefore native forest internationally recognized GPS coordinates. cannot be deforested even if an official land use map (Option 1) permits this. 4.4.1.2 c) Option 1: Maps used for this purpose have been subject to adequate and effective public consultation. 4.4.1.2 c) Option 2: HCVA assessment should be undertaken using the existing guidance e.g. HCV Toolkit. The assessors should be recognized by RTRS or the HCV network. Definition of native forest: areas of native vegetation of 1ha or more with canopy (...) 30 ProTerra V2.9 (...) conventions that pose additional limits on conversion of native vegetation to agricultural or other commercial purposes must also be heeded. RTRS V1 (...) cleared of native habitat except under the following conditions: 4.4.1.1 It is in line with an RTRS-approved map and system (see Annex 4.) or 4.4.1.2 Where no RTRS-approved map and system is available: a) Any area already cleared for agriculture or pasture before May 2009 and used for agriculture or pasture within the past 12 years can be used for soy expansion, unless regenerated vegetation has reached the definition of native forest (see glossary). b) There is no expansion in native forests (see glossary) c) In areas that are not native forest (see glossary), expansion into native habitat only occurs according to one of the following two options: Option 1. Official land-use maps such as ecological-economic zoning are used and expansion only occurs in areas designated for expansion by the zoning. If there are no official land use maps then maps produced by the government under the Convention on Biological Diversity (CBD) are used, and expansion only occurs outside priority areas for conservation shown on these maps. Option 2. An High Conservation Value Area (HCVA) assessment is undertaken prior to clearing and there is no conversion of High Conservation Value Areas. Note: Where neither official land use maps nor CBD maps exist, Option 2 must be followed. ProTerra Guidance RTRS Guidance Comments (...) cover of more than 35 % and where some trees (at least 10 trees per hectare) reach 10m in height (or are able to reach these thresholds in situ (ie. in that soil/climate combination). Examples of native forests include Amazon, Mata Atlantica, Yungas, Chiquitano, forest areas of NE China Data capture requirements for future Payment for Environmental Services (PES) schemes: The date of registration of the producer for certification is recorded by the certification body. During the certification audit, the area and type of vegetation of all voluntary reserves of native vegetation (above the legal requirement) are recorded. Following certification, details of the date of registration for certification and the area and type of vegetation of voluntary reserves are added to an RTRS register. When an RTRS PES scheme is developed, payments are available retroactively to the date of registration for certification to all producers on the register. (...) for determining if land constitutes native habitat or native forest which is based on the judgement of “experts.” 3. RTRS allows clearing of other native habitat based on land use mapping that is established by local government and is subject to influence by interested parties or based on a HCVA analysis, which is, again, subjective because it is dependent on the judgement of “experts.” 4. RTRS specifies that the “experts”“should be recognized by RTRS or the HCV network.” However, RTRS has no system for qualifying such experts and the HCV website simply has a list of self-nominated individuals and state they take no responsibility for evaluating their credentials. 31 ProTerra V2.9 RTRS V1 10.1.2 In all cases where clearing of HCVAs has already been done after 1994, certified operations must implement compensatory measures to restore appropriate parts of the cleared areas according to national law, or in cases where national law does not address this point, the Environmental Management Plan shall define a program of compensatory measures that are relevant to the local ecosystem and assure the ability of the ecosystem to continue to deliver essential environmental services. 10.2 Part of the environmental impact assessment described in 9.1 will be to develop, document, and implement a plan to maintain and maximize biodiversity within and surrounding the operation, which will be updated yearly. ProTerra Guidance RTRS Guidance Comments Two aspects of the compensatory measures must be considered: i. The type and place of restoration – areas as described in section 10.1 above should be re-vegetated with native species appropriate to the zone in question, preferably to reproduce as much as possible what was originally destroyed. ii. The percentage of the originally cleared area that must be restored – this will depend on local, regional, national, and/ or international laws and/or conventions as applicable to the biome in question. For example certified organizations will protect areas that are: (a) designated by law or by the relevant competent authority for nature protection purposes; or (b) designated for the protection of rare, threatened or endangered ecosystems or species recognized by international agreements or included in lists drawn up by intergovernmental organizations or the International Union for the Conservation of Nature. 4.5 On-farm biodiversity is maintained and safeguarded through the preservation of native vegetation. 4.5.1 There is a map of the farm which shows the native vegetation. 4.5.2 There is a plan, which is being implemented, to ensure that the native vegetation is being maintained (except areas covered under Criterion 4.4). This criterion shall be applied with reference to the complexity and size of the organization. ProTerra is more stringent than RTRS in this area. Whereas ProTerra requires that the certified operation maintain and maximize biodiversity in and around the operation, RTRS only considers biodiversity on the farm, not in the surroundings, and only requires that the operator maintain whatever biodiverrsity remains at the time of first certification. ProTerra V2.9 RTRS V1 10.2.1 Certified organizations shall maintain or restore areas of natural vegetation around bodies of water and on steep slopes and hills, and other sensitive parts of the ecosystem. 5.2 Natural vegetation areas around springs and along natural watercourses are maintained or re-established. ProTerra Guidance RTRS Guidance The width or area of vegetation shall be sufficient to maintain and foster the continued survival of the natural biodiversity of the area and to avoid erosion. RTRS requires vegetation buffers around riperian areas, whereas ProTerra requires preservation or restoration of natural vegetation on other sensitive parts of the ecosystem as well as in riperian areas. RTRS specifies details regarding riperian areas that ProTerra does not mention in these clauses, but which would be fulfilled by the environmental impact assessment specified in ProTerra 9.1 5.2.1 The location of all watercourses has been identified and mapped, including the status of the riparian vegetation. 5.2.2 Where natural vegetation in riparian areas has been removed there is a plan with a timetable for restoration which is being implemented 5.2.3 Natural wetlands are not drained and native vegetation is maintained. 10.2.2 Certified organizations shall gather wild species or products from wild areas only when permitted by law and shall do so only in a manner that assures those species will continue to flourish in their natural habitat along with other species that normally depend on the gathered species. 10.2.3 The introduction of invasive species and new pests shall be avoided, and past introductions must be controlled and monitored, and any invasive expansion of these shall be reported to the authorities. 4.5.3 No hunting of rare, threatened or endangered species takes place on the property. 5.8 Systematic measures are planned and implemented to monitor, control and minimize the spread of invasive introduced species and new pests. 5.8.1 Where there are institutional systems in place to identify and monitor invasive introduced species and new pests, or major outbreaks of existing pests, producers follow the requirements of these systems, to minimize their spread. 5.8.2 Where such systems do not exist, incidences of new pests or invasive species and major outbreaks of existing pests are communicated to the proper authorities and relevant producer organizations or research organizations. Comments RTRS and ProTerra are generally equivalent. Note: For group certification - the group manager is responsible for communicating to the authorities and relevant organizations. ProTerra and RTRS are equivalent. 32 33 ProTerra V2.9 RTRS V1 11.1 Genetically modified organisms (GMO) and their byproducts must not be used in the production of ProTerra certified products. RTRS Guidance Comments No Corresponding Principle Preamble PRINCIPLE 11 - Genetically Modified Organisms (GMO) not used ProTerra Guidance Scope of application: This standard applies to all kinds of soybeans, including conventionally grown, organic, and genetically modified (GM). It has been designed to be used for all scales of soy production and all the countries where soy is produced. This requirement applies to seed and other agricultural inputs, as well as ingredients, processing aids, additives, and other inputs used in processing agricultural products and used in manufacturing food, feed, fibber, and fuel products. 11.1.1 All certified organizations shall avoid the unintentional contamination of certified products by GMO’s from external sources. The rejection threshold for inadvertent contamination of inputs and products with GM materials shall be 0.1% for products for which the producer intends to make a nonGMO claim. In cases where a production system is designed to exclude GMOs to the 0.1% threshold, occasional lots that exceed this threshold but contain less than 0.9% GMO can be accepted under the ProTerra Certification Program. Such products qualify under EU law as “compliant with EU labelling requirements for non-declaration of GMOs,” but cannot carry a non-GMO claim. 11.1.2 Certified organizations must demonstrate compliance to Section 11 of this Standard in a manner commensurate with the level of GMO risk involved. Specifically: a. If any product is not listed in Appendix B and if the inputs used in making that product are not listed in Appendix B, then the product is considered to have low GMO risk and no further action is required to fulfil the requirements of Section 11.1 and 11.1.1 b. If a product or the inputs from which it is produced are listed in Appendix B, (...) Refer to Appendix B: List of Crops and Derivatives with GMO Risk, to determine if the certified operation is involved with such high-risk materials. The standards and requirements for the CERT ID Non-GMO certification program are available directly from CERT ID. Certification to the CERT ID Non-GMO Standard (0.1% tolerance threshold) allows the certified organization to make a nonGMO claim. Within a system designed to operate to a threshold of 0.1%, occasional lots of material may contain more GM (...) RTRS allows for the certification of GMO soy whilst ProTerra only allows for the certification of conventional crops and byproducts, in alignment with the original Basel Criteria for the Responsible Production of Soy. ProTerra is also significantly more rigorous notably regarding Identity Preservation (IP) across all stages of the supply chain. (...) 34 ProTerra V2.9 RTRS V1 (...) the requirements of Section 11 shall be fulfilled by undergoing certification according to the CERT ID Non-GMO Standard which is herby incorporated by reference and made an integral part of the ProTerra Standard. PRINCIPLE 12 - Waste and pollution managed effectively 12.1 Certified organizations shall minimize the use of waste materials and pollutants and shall handle, store and dispose of these materials properly. 12.1.1 Non-biological wastes shall be segregated and, where appropriate, recycled. If recycling is not possible, a legal means of disposal or a legal alternative use shall be employed. 12.2 Certified organizations shall manage biological wastes (e.g., manure, straw, harvest plant residues, and processing by products thereof) appropriately to avoid pollution and/or to prevent these from becoming a source of pathogenic contamination or pest harborage. ProTerra Guidance RTRS Guidance Comments (...) material at levels greater than 0.1% but less than 0.9%. Such lots cannot according to EU law, carry the claim “Non-GMO,” but do comply with EU regulations allowing “non-declaration of the presence of GM material” if the GMO content can be demonstrated to be below 0.9% and if a evidence can be provided that the material was produced in a system designed to deliver product with GM content of 0.1% or lower. (...) These waste materials include but are not limited to pesticides, fertilizers, processing aids, cleaning products, detergents, and oil derivatives. ProTerra and RTRS are equivalent. Principle 4: Environmental Responsibility Principle 5: Good Agricultural Practice 4.2 Pollution is minimized and production waste is managed responsibly 4.2.2 There is adequate storage and disposal of fuel, batteries, tires, lubricants, sewage and other waste. 4.2.4 Provide information on existing programs for re-using or recycling waste products. ProTerra and RTRS are equivalent. ProTerra is more specific. 4.2.5 For large and medium producers this should be documented. For small farms it is sufficient that the producer knows what residues are produced and what will be done with each one. ProTerra and RTRS are equivalent, however RTRS restricts the focus to crop residues, while ProTerra addresses all biological wastes, including the important category of processing wastes. 4.2.4 Re-use and recycling are utilized wherever possible. 4.2.5 There is a residue management plan including all areas of the property. 35 ProTerra V2.9 12.2.1 Biological wastes shall not be incinerated, except when required for phytosanitary purposes, or in some cases when burned for energy or heating. RTRS V1 4.2.1 There is no burning on any part of the property of crop residues, waste, or as part of vegetation clearance, except under one of the following conditions: a) Where there is a legal obligation to burn as a sanitary measure; b) Where it is used for generation of energy including charcoal production and for drying crops; c) Where only small-caliber residual vegetation from land clearing remains after all useable material has been removed for other uses. 12.2.2 Certified organizations shall discharge sewage water/effluents in a manner that does not cause pollution to water supplies for human beings or animals, and does not contaminate the soil or crops with chemicals, heavy metals, by-products, or excess nutrients and pathogens. Raw sewage shall not be used to irrigate crops. ProTerra Guidance RTRS Guidance Comments Burning for energy production shall be practiced only in cases where sufficient biomass can also be recycled to the fields by composting or other methods for effectively building healthy soil. ProTerra and RTRS are equivalent, except that RTRS allows use of burning as part of the land clearing and land conversion process, while ProTerra does not, as specified in ProTerra 15.2. If sewage is to be used or otherwise incorporated back into any production system, it must be treated such that it complies with the requirement. No corresponding requirement exists in the RTRS Standard. Certified organizations shall ensure that sewage water is treated and filtered to assure that water that is released back into the environment is safe. 4.2.3 There are facilities to prevent spills of oil and other pollutants. ProTerra and RTRS are equivalent. Spill prevention facilities are not mentioned explicitly in ProTerra, but coverred under 4.1.1, which addresses procedures and systems for managing emergencies. 36 ProTerra V2.9 RTRS V1 ProTerra Guidance 12.2.3 Certified organizations shall monitor physical, chemical and biological characteristics of water discharged into the environment to ensure safety and legal compliance. 5.1 The quality and supply of surface and ground water is maintained or improved. COD or BOD and also N and P concentrations must not exceed local environmental regulations. 5.1.1 Good agricultural practices are implemented to minimize diffuse and localized impacts on surface and ground water quality from chemical residues, fertilizers, erosion or other sources and to promote aquifer recharge. 5.1.2 There is monitoring, appropriate to scale, to demonstrate that the practices are effective. RTRS Guidance Comments RTRS and ProTerra are equivalent. 5.1.2 Where appropriate there should be monitoring of parameters such as pH, temperature, dissolved oxygen, turbidity and electrical conductivity. Monitoring should be considered at watershed level. 5.1.2 Where there are wells these should be used to monitor ground water. 5.1.3 Any direct evidence of localized contamination of ground or surface water is reported to, and monitored in collaboration with local authorities. 12.3 Water, soil, pests, fertility and irrigation shall be managed such that surface and ground water and other water supplies are not contaminated. 12.4 Certified organizations shall implement systems and procedures to ensure that concentrations of contaminants emitted through smoke pipes, chimneys, boilers, ovens, incinerators, and electricity generators do not exceed established limits set by local or national law. 12.4.1 Certified organizations shall not reduce the effectiveness of control systems to accelerate production flow or to improve other performance parameters of the operating system, unless necessary under short term emergency conditions. 5.1 The quality and supply of surface and ground water is maintained or improved. Testing shall be done to assure that contamination does not occur. RTRS and ProTerra are equivalent. Certified organizations shall document the performance of these control systems. No corresponding requirement exists in the RTRS Standard. At the end of emergency conditions, the control systems shall be restored to optimal performance. No corresponding requirement exists in the RTRS Standard. 37 ProTerra V2.9 12.5 Growers shall avoid or reduce the use of toxic or polluting materials whenever possible, and shall select agrochemical inputs having the least possible toxicity and environmental impact for the required application. 12.5.1 Pesticides listed on the WHO class 1 a & b, Pesticide Action Network’s “Dirty Dozen” list, and FAO/UNEP's Prior Informed Consent Procedure, on the Rotterdam Convention and on the Stockholm Convention, may not be used. Hazardous substances listed on the Rotterdam Convention are not to be used in agricultural or industrial operations. 12.5.2 In cases where chemicals included on the lists cited in 12.5.1 can be used legally in the country where agricultural production is conducted, certified organizations shall implement a program of progressive reduction of use over time, which will be agreed with the certification body and tracked on a yearly basis. In such cases, products exported to countries where said pesticides are not allowed by law shall be tested before export to assure that residue levels are negligible or are, at least, compliant with residue limits set in the country of import. RTRS V1 ProTerra Guidance 5.4.2 There is an implemented plan that contains Operations that use agrochemicals shall targets for reduction of potentially harmful employ Integrated Pest Management and phytosanitary products over time. other strategies to minimize agrochemical use. 5.6 Agrochemicals listed in the Stockholm and Rotterdam Conventions are not used. Lists of all chemicals referenced in this requirement may be found in Appendix C of this Standard and by searching on the websites listed at the end of Appendix C. RTRS Guidance Comments 5.4.2 The parameters that are monitored RTRS and ProTerra are include the number of applications of generally equivalent. phytosanitary products per crop cycle, volume of phytosanitary product used per hectare and toxicological class of product. 5.4.2 The level of potential harmfulness of a phytosanitary product can be determined from its WHO class for the purposes of this criterion. 5.4.2 Where targets are not met, documented evidence is presented to justify this. RTRS and ProTerra are generally equivalent. ProTerra is more restrictive. No corresponding requirement exists in the RTRS Standard. 38 ProTerra V2.9 12.5.3 The use of pesticides for pests, diseases, and non-crop plants shall be minimized through integrated pest management (IPM), and use of ecologically sound biological controls for the target pest or disease where applicable. RTRS V1 ProTerra Guidance RTRS Guidance Comments 5.4 Negative environmental and health impacts of phytosanitary products are reduced by implementation of systematic, recognized Integrated Crop Management (ICM) techniques. Note: See Annex 5 for further information on ICM. Note: For group certification of small farms - (particularly those who are not literate) the development and documentation of the ICM plan should be undertaken by the group manager, together with support for implementation. Surface and ground water includes lakes, rivers, lagoons, marshes, swamps, ground water sources, aquifers/water tables. RTRS and ProTerra are equivalent. 5.7 The use of biological control agents is documented, monitored and controlled in accordance with national laws and internationally accepted scientific protocols. Records of use of biological control agents should be used as evidence of compliance with this criterion Both RTRS and ProTerra advocate use of biological control of pests, however, RTRS provides more detailed guidance on use. 5.7.1 There is information about requirements for use of biological control agents 5.7.2 Records are kept of all use of biological control agents that demonstrate compliance with national laws. Scale and context, especially for small farms, should be taken into account. 12.5.4 Certified organizations shall use nonchemical weed control methods whenever possible, such as mechanical methods and management of crop rotations, crop succession and intercropping. 5.4.1 A plan for ICM is documented and implemented which addresses the use of prevention, and biological and other nonchemical or selective chemical controls. Operations that use agrochemicals should make stepwise changes in their systems to significantly minimize or eliminate the need for herbicides. 12.5.5 Certified organizations shall only use pesticides on crops and for target species for which they are legally allowed, at the prescribed dosage, during the required timeframe and/or crop conditions, as defined in local laws and regulations and by manufacturers’ recommendations or by documented best practices. 5.4.3 Use of phytosanitary products follows legal requirements and professional recommendations (or, if professional recommendations are not available, manufacturer’s recommendations) and includes rotation of active ingredients to prevent resistance. This will include a program of pesticide rotation designed to minimize development of pest resistance. Note: For group certification of small farms - (particularly those who are not literate) the development and documentation of the ICM plan should be undertaken by the group manager, together with support for implementation. RTRS and ProTerra are equivalent. RTRS and ProTerra are equivalent. 39 ProTerra V2.9 RTRS V1 12.6 Agrochemicals shall be applied using methods that minimize harm to human health, wild life, plant biodiversity, and water and air quality. 5.9 Appropriate measures are implemented to prevent the drift of agrochemicals to neighboring areas. 12.6.1 Certified organizations shall not engage in pesticide spraying over bodies of water, or over preserved, protected or residential areas. RTRS Guidance Factors that influence drift include among others wind speed and direction, temperature, equipment utilized and topography, Requirements for small farms should be appropriate to scale and context. For group certification of small farms group managers may provide documented procedures and maintain records of weather conditions. 5.9.5 There is no application of pesticides within 30m of any populated areas or water bodies. Note: ‘Populated areas’ means any occupied house, office or other building. Note: ‘Water bodies’ includes, but is not limited to, water courses, rivers, streams, lagoons, springs, lakes, reservoirs and ditches. 5.9.5: There may be an exception for manual application of chemicals not classified as WHO Ia, Ib, or II, if adequate measures are taken to prevent drift (e.g. use of backpack applicators with shields) and it is permitted by the law and manufacturer’s recommendations. 12.6.3 Recently sprayed areas shall be marked appropriately to warn people not to enter into such areas. 5.5.4 The necessary precautions are taken to avoid people entering into recently sprayed areas. 12.6.4 Aerial spraying shall be conducted only under weather conditions that minimize drift to adjacent areas. 5.9.3 Aerial application of pesticides is carried out in such a way that it does not have an impact on populated areas. All aerial application is preceded by advance notification to residents within 500m of the planned application. Comments RTRS and ProTerra are equivalent. 5.9.1 There are documented procedures in place that specify good agricultural practices, including minimization of drift, in applying agrochemicals and these procedures are being implemented. 12.6.2 Pesticides shall not be sprayed within 100 meters of human populated areas, and shall not be sprayed within 50 meters of bodies of water. 12.6.5 Residents within 1 km shall be informed at least one day in advance before aerial spraying is done. ProTerra Guidance RTRS and ProTerra are generally equivalent. RTRS and ProTerra are roughly equivalent. But RTRS prescribes only 30 m while ProTerra prescribes 100 m from populated areas and 50 m from bodies of water. RTRS and ProTerra are equivalent. Note: ‘Populated areas’ means any occupied RTRS and ProTerra are roughly house, office or other building. equivalent, but ProTerra requires larger protective distances. 40 ProTerra V2.9 RTRS V1 12.6.6 Aerial spraying shall not be carried out with WHO Class II pesticides. 5.9.4 There is no aerial application of pesticides in WHO Class Ia, Ib and II within 500m of populated areas or water bodies. ProTerra Guidance RTRS Guidance Generally equivalent for ProTerra and RTRS. ProTerra is more protective. 12.6.7 Certified organizations shall adhere to quarantine periods, avoiding harvest until applied pesticide hazard for consumers is reduced to acceptable levels. 12.6.8 Pesticides shall be handled, stored, transported, and disposed of according to manufacturers’ instructions, legal requirements, or according to procedures documented to be superior. No corresponding requirement exists in RTRS 5.5.2 Containers are properly stored, washed and disposed of; waste and residual agrochemicals are disposed in an environmentally appropriate way. 5.5.3 Transportation and storage of agrochemicals is safe and all applicable health, environmental and safety precautions are implemented. 12.6.9 Certified organizations shall maintain, for a period of at least 5 years, records of all pesticides, other agrochemicals and other inputs purchased, used, and disposed of, including bio-control agents. Records of pests, diseases, weather conditions during spraying, and weeds shall also be recorded. Comments 5.5.1 There are records of the use of agrochemicals, including: a) products purchased and applied, quantity and dates; b) identification of the area where the application was made; c) names of the persons that carried out the preparation of the products and field application; d) identification of the application equipment used; e) weather conditions during application. Pesticides shall be stored and transported in original containers or in other appropriate containers clearly labelled to identify contents. Growers shall follow manufacturer’s recommendations and legal requirements for disposing of agrochemical wastes and empty pesticide containers, and for cleaning all application equipment. Growers shall triple rinse empty pesticide containers with water, then perforate to prevent reuse, and when possible return containers to the supplier, or to facilities designed to handle such wastes. 5.5.2 Washing of containers should be carried out using triple rinsing principles (including re-use of the rinse water in the tank mix) or using high-pressure techniques associated with mechanical application. Documentation will include at least the following: · Application procedures · Dilution dosages and amounts used · Crops and field locations to which they were applied · Dates of application · Relevant quarantine times before the crop was harvested · Weather conditions during application. 5.5.1 Records are maintained for at least 5 years. This does not apply to records from years prior to certification. 5.5.1 Scale and context, especially for small farms, should be taken into account. Exceptions (e.g. for maintaining invoices) may be allowed for small farms in a group, provided that the group has a mechanism for assuring compliance with the criterion. RTRS and ProTerra are equivalent. 5.5.3 Areas used for the storage and distribution of agrochemicals, flammable and toxic substances are designed, constructed and equipped to reduce the risks of accidents and negative impacts on human health and the environment. RTRS and ProTerra are generally equivalent. 41 ProTerra V2.9 RTRS V1 ProTerra Guidance RTRS Guidance 5.5 All application of agrochemical is documented and all handling, storage, collection and disposal of chemical waste and empty containers, is monitored to ensure compliance with good practice. 5.9.2 Records of weather conditions (wind speed and direction, temperature and relative humidity) during spraying operations are maintained. 12.7 Best practices are followed in fertilizer use, based on expert opinion or at least the manufacturer's recommendations. PRINCIPLE 13 - Water managed conservatively 13.1 Certified organizations (Levels I, II and III) shall conserve quantity and quality of existing natural water resources, such as lakes, rivers, artificial lakes, dams, water tables and aquifers around their facilities. Requirements for small farms should be appropriate to scale and context. For group certification of small farms - group managers may provide documented procedures and maintain records of weather conditions. 5.5.5 Fertilizers are used in accordance with professional recommendations (provided by manufacturers where other professional recommendations are not available). 12.8 Level III organizations shall test agricultural produce on receipt for chemical residues (e.g., pesticides) and harmful contaminants (e.g., mycotoxins), and maintain testing records. Comments Equivalent to ProTerra 12.6 to 12.6.9 Corresponds to ProTerra 12.6.9, but is more detailed. RTRS and ProTerra are equivalent. Tests should be designed so that they are as relevant as possible to the specific risks involved. Frequency of tests shall be determined on the basis of a risk analysis conducted by the operation and evaluated by the certification body. No corresponding requirement exists in RTRS because RTRS does not apply to Level III organizations. Principle 4: Environmental Responsibility Principle 5: Good Agricultural Practice 5.1 The quality and supply of surface and ground water is maintained or improved. 5.1.3 Any direct evidence of localized contamination of ground or surface water is reported to, and monitored in collaboration with local authorities. Note: For group certification of small farms - Where irrigation is used for crops other than soy but is not done according to best practice, a plan is in place and is being implemented to improve practices. The group manager is responsible for documentation. RTRS and ProTerra are equivalent. RTRS makes reference to potential improvements in water quality No corresponding requirement exists in ProTerra. 42 ProTerra V2.9 RTRS V1 13.1.1 Certified organizations shall not undertake new initiatives that reduce the availability of water for neighboring communities and farms for drinking and irrigation, or for "traditional" uses. ProTerra Guidance “Traditional” uses of water by certified operators must likewise be shown to still be viable and sustainable. Practices that once were considered sustainable may no longer be due to increased population pressure or other recent ecosystem or climatic changes. 13.1.2 In cases where activities that predate the certification application damage water resources, certified organizations shall undertake improvements in practices according to an agreed time frame that will rectify such interference. RTRS Guidance Comments No corresponding requirement exists in RTRS. No corresponding requirement exists in RTRS. 13.2 Certified organizations shall implement best practices for water management on the farm. 5.1.1 Good agricultural practices are implemented to minimize diffuse and localized impacts on surface and ground water quality from chemical residues, fertilizers, erosion or other sources and to promote aquifer recharge. RTRS and ProTerra are equivalent. 13.2.1 Certified organizations shall implement best practices for irrigation. 5.1.4 Where irrigation is used, there is a documented procedure in place for applying best practices and acting according to legislation and best practice guidance (where this exists), and for measurement of water utilization. 5.1.4 When using irrigation, attention RTRS and ProTerra are should be paid to other potential uses such equivalent. as household use or use by other food crops and if there is a lack of water priority should be given to human consumption. 13.2.2 Certified organizations shall implement recycling systems and strategies to promote aquifer and water table recharge according to an agreed timeline. 5.1.1 Good agricultural practices are implemented to minimize diffuse and localized impacts on surface and ground water quality from chemical residues, fertilizers, erosion or other sources and to promote aquifer recharge. RTRS and ProTerra are equivalent. 13.2.3 Irrigation shall be managed so as to avoid contamination, salinization and desertification of the soil. No corresponding requirement exists in RTRS 43 ProTerra V2.9 PRINCIPLE 14 - Greenhouse gasses and energy managed effectively 14.1 Certified organizations shall monitor greenhouse gas emissions and observe restrictions and limits in order to minimize climate change impacts. RTRS V1 RTRS Guidance Comments Principle 4: Environmental Responsibility 4.3 Efforts are made to reduce emissions and increase sequestration of Greenhouse Gases (GHGs) on the farm. 14.1.1 If products are used that are classified as destructive to the ozone layer, a schedule for their elimination and replacement, as described by the Montreal Protocol, shall be followed. Examples of such products are Chlorofluorocarbons (CFCs), halons, Hydrochlorofluorocarbons (HCFCs) and Hydrobromofluorocarbons (HBFCs). 14.1.2 Certified organizations shall monitor and reduce greenhouse gas emissions such as carbon dioxide, methane, nitrogen and sulphur oxides, etc., through effective management of energy, soil, fertilizers, native biodiversity and other practices. ProTerra Guidance Note: Other issues which are relevant RTRS and ProTerra are to GHG emissions are covered in other equivalent. principles including: Use of fertilizers (Criterion 5.5), Land-use change (Criterion 4.4). On farms which produce multiple crops an estimate of the use of fossil fuel for soy production should be calculated. ‘Activities related to soy production’ include: field operations and on-farm transport, whether this is done by the producer or by third parties. An example of a justification for an increase in the intensity of fossil fuel use may be if a planting was lost due to drought and had to be replanted. The use of renewable energy (biofuels, biogas, solar and wind energy etc) on the farm is encouraged. In the case of renewable energy replacing electricity, quantify the equivalent fossil fuel saving. No corresponding requirement exists in RTRS 4.3 Efforts are made to reduce emissions and increase sequestration of Greenhouse Generally equivalent. ProTerra has a more complete requirement whereas RTRS emphasis fossil fuel usage only. 44 ProTerra V2.9 14.2 Over time, certified organizations shall adopt practices to minimize the use of energy, especially energy from nonrenewable sources and to derive an increasing proportion of their energy from renewable sources such as solar and wind, or from local, recycled materials. RTRS V1 ProTerra Guidance RTRS Guidance 4.3.3 Soil organic matter is monitored to quantify change in soil carbon and steps are taken to mitigate negative trends. Broad equivalence between RTRS 4.3.3 and ProTerra 14.1.1 4.3.4 Opportunities for increasing carbon sequestration through restoration of native vegetation, forest plantations and other means are identified. Broad equivalence between RTRS 4.3.4 and ProTerra 14.1.1 4.3.1 Total direct fossil fuel use over time is recorded, and its volume per hectare and per unit of product for all activities related to soy production is monitored. Examples of applicable materials are reforestation wood, bio-fuels, wood chips, and crushed sugarcane fiber. RTRS focuses on fossil fuel use, requiring monitoring, and allows increases in fossil fuel use with justification. In contrast, ProTerra requires reductions over time in energy use and especially reduction of all forms of nonrenewable energy, not just fossil fuels. Plans should identify timelines, methods, and proposed budgeting of time and company resources needed. Progress shall be documented or otherwise demonstrable. 4.3.2 If there is an increase in the intensity of fossil fuel used, there is a justification for this. If no justification is available there is an action plan to reduce use. PRINCIPLE 15 - Good agricultural practices adopted 15.1 Growers shall adopt agricultural best practices and, where possible, adopt conservation systems such as Integrated Pest Management (IPM) and organic agricultural practices. Comments Princilple 5: Good Agricultural Practice 5.5 All application of agrochemicals2 is documented and all handling, storage, collection and disposal of chemical waste and empty containers, is monitored to ensure compliance with good practice. Best practices include methods that build soil, protect water, reduce chemical usage, and foster biodiversity. 2 Note: Agrochemicals refers to all chemicals used including fertilizers and pesticides. RTRS and ProTerra are generally equivalent regarding agricultural best practices, except that ProTerra sets more ambitious progressive targets. 45 ProTerra V2.9 15.2 Certified organizations shall not clear areas by burning vegetation except when this method is prescribed by experts as the optimal ecological option. RTRS V1 ProTerra Guidance 4.2.1 There is no burning on any part of the Such recommendations shall be property of crop residues, waste, or as part documented. of vegetation clearance, except under one of the following conditions: a) Where there is a legal obligation to burn as a sanitary measure; b) Where it is used for generation of energy including charcoal production and for drying crops; c) Where only small-caliber residual vegetation from land clearing remains after all useable material has been removed for other uses. RTRS Guidance Comments Generally equivalent, but RTRS has more exceptions to the prohibition on use of burning for land clearance. 15.2.1 If experts recommend fire as the most appropriate option for clearing an area, then trained people shall apply the technical procedure and employ all required safety and environmental measures. Terms for qualifications shall be described by the certified operation. No corresponding requirement exists in RTRS 15.2.2 Although burning may be recommended for a specific current application, certified organizations shall develop alternative methods for use in future years. The development of alternative practices should commence within the year that burning is employed, and should be completed on a timeline, defined in consultation with the certification body. No corresponding requirement exists in RTRS 5.3 Soil quality is maintained or improved and erosion is avoided by good management practices. Examples of useful practices include use of cover crops, management of vegetation, management of crop succession and rotation. RTRS and ProTerra are equivalent (see also ProTerra 15.3.2). 15.3.1 Certified organizations shall evaluate suitability of the soil for production of specific crops and to define a soil management regime. 5.3.1 Knowledge of techniques to maintain soil quality (physical, chemical and biological) is demonstrated and these techniques are implemented. Expert advice on soil science can be accessed outside the organization if not available on site and soil analysis can be a useful tool for this evaluation. RTRS and ProTerra are equivalent. 15.3.2 Certified organizations shall minimize soil erosion and damage to soil structure caused by wind, water, human activity and presence of farm animals. 5.3.2 Knowledge of techniques to control soil erosion is demonstrated and these techniques are implemented. Production practices should maintain vegetative cover for as long as possible throughout the year. RTRS and ProTerra are equivalent. 15.3 Certified organizations shall define a soil and crop management regime that monitors soil quality, builds soil, enhances fertility and manages pests and diseases. 46 ProTerra V2.9 RTRS V1 5.3.3 Appropriate monitoring, including soil organic matter content, is in place. ProTerra Guidance RTRS Guidance Note: For group certification - Monitoring of soil fertility and soil quality should be part of the internal control system and can be carried out on a sampling basis within the group. 15.4 Certified organizations shall maintain 5.4.4 Records kept in several areas relevant to records of all agricultural production for a agricultural practices. minimum of 5 years or longer if specified by local regulations. Records include: - Production and yields of the farm by lot, including seed variety, production and storage periods, and delivery destinations - Crop succession and rotation for each field - Fertilizer and pesticide applications - Pests and diseases - Other soil and crop status and management practices 15.5 Managing propagation materials including seeds, stem cuttings, rootstock, etc. shall be an integral part of the systemic management of the agricultural operation. 15.5.1 Seeds, seedlings, and propagation materials shall be selected for quality and performance for the locale. 15.5.2 Seed-saving and local breeding are acceptable procedures however, the certified organization must conduct practices to assure seed quality and performance. 5.11 Origin of seeds is controlled to improve production and prevent introduction of new diseases. 5.11.1 All purchased seed must come from known legal quality sources. 5.11.2 Self-propagated seeds may be used, provided appropriate seed production norms are followed and legal requirements regarding intellectual property rights are met. Comments Equivalent to ProTerra 15.3 and 15.5. RTRS requires record keeping in 5.4.4, 5.5.1, 5.7.2, and 5.9.2 The certification body may wave this Consider pest and disease resistance, requirement in cases where producers save and adaptation to local climactic and soil their own seed or propagate from their own conditions. existing stocks, especially in the case of smallholders. RTRS and ProTerra generally equivalent. 47 ProTerra V2.9 RTRS V1 ProTerra Guidance RTRS Guidance Comments 15.5.3 Certified organizations shall maintain all seed records for a minimum of 5 years or longer if specified by local regulations. Records include: - Seed certificates - Records of seeds produced for farm - Each season’s records identifying the seeds and their source used for planting each crop If this requirement is first being met during the initial year that ProTerra certification is achieved, the certification body will waive the retroactive aspect of it for the initial years of certification. No corresponding requirement exists in RTRS 15.5.4 Certified organizations shall retain archive seed samples for a minimum of 2 years, or longer if specified by local regulations. The certified organization must begin archiving seed during the first year of certification, and maintain archives for two years. No corresponding requirement exists in RTRS PRINCIPLE 16 - Traceable and segregated chain of custody No Corresponding Principle 16.1 Certified organizations shall ensure that all products certified to the ProTerra Standard and inputs used in such products can be traced back to the farm. 16.1.1 Certified organizations shall maintain traceability records for a minimum period of 5 years, or longer, if required by local legislation. If this requirement is first being met during the initial year that ProTerra certification is achieved, the certification body will waive the retroactive aspect of it for the first years of certification. 16.1.2 Certified producers shall maintain seed records for a minimum of 5 years or longer if specified by local regulations. Records include: - Seed certificates for purchased seeds - Records of seeds produced on the farm - Records identifying the seeds used for each crop If this requirement is first being met during the initial year that ProTerra certification is achieved, the certification body will waive the retroactive aspect of it for the first years of certification. 16.1.3 Certified producers shall maintain production and storage records for each crop for a minimum of 5 years or longer if specified by local regulations. If this requirement is first being met during the initial year that ProTerra certification is achieved, the certification body will waive the retroactive aspect of it for the first years of certification. No corresponding requirement exists in RTRS production standard, RTRS Chain of Custody Standard addresses traceability but this standard’s most rigorous option is not as stringent than ProTerra, while other options are much less stringent. (...) 48 ProTerra V2.9 16.1.4 Records at first point of sale. Each truck or other conveyance that unloads agricultural commodities at an elevator or warehouse shall be weighed. Control documents will record weight, lot number, date, driver name, number of vehicle license plates, farm name, number of silo or warehouse and locality, as well as analytical results, if any, regarding quality and identity of crop and will be kept for 5 years or longer if specified by local regulations. RTRS V1 ProTerra Guidance Product will be delivered either directly from the farm or from another warehouse or silo. These are truckload by truckload records connecting producer-seller with the processor-buyer. If this requirement is first being met during the initial year that ProTerra certification is achieved, the certification body will waive the retroactive aspect of it for the first years of certification. 16.1.5 The receiving certified organization shall assign a lot number to each shipment linked to the identification information listed above. 16.2 The chain of custody for ProTerra certified products shall be fully traceable and documented and shall be fully segregated from non-ProTerra materials. Fulfillment of the requirements outlined in 16.2 and 16.2.1 through 16.2.5 qualify an Economic Operator as a ProTerra Chain of Custody Economic Operator. Fulfillment of these requirements shall enable the Economic Operators to make a sustainability claim on final products offered to consumers and on any intermediate product as well. 16.2.1 The Economic Operator shall have, and shall consistently employ, standard operating procedures for maintaining full segregation for each lot of ProTerra certified product from the point of receipt to the point of transfer to the next Economic Operator in the supply chain. 16.2.2 The Economic Operator shall maintain and update records that document full traceability throughout that segment of the supply chain for which that Economic Operator is responsible. RTRS Guidance Comments (...) 49 ProTerra V2.9 16.2.3 Chain of Custody traceability shall be maintained during transfer of ownership of a consignment of ProTerra certified product from one Economic Operator to another by means of a Transaction Certificate of Compliance (TCC) specific for that transaction. RTRS V1 ProTerra Guidance The information contained in the Traceability Certificate of Compliance shall include the volume of the consignment changing ownership, the lot numbers and the volumes of each lot of material contained in the consignment, the identity of the receiving and supplying economic operators, and the date of the transaction. This information shall be retained by both Economic Operators. A ProTerra Chain of Custody Economic Operator can receive consignments of ProTerra certified products consisting of defined volumes derived from one or more production lots, and can merge or split received consignments of ProTerra certified materials. To each new merged or split consignment a unique identification number must be assigned. Use of TCCs is not required for sealed products that are packaged and labelled for the end user, for example, retail packages. 16.2.4 The Economic Operator shall maintain and update inventory control documentation assuring that volumes of ProTerra certified material received are equal to volumes disbursed. 16.2.5 In the case of ProTerra certified materials that have GMO risk (such as soy meal or soy lecithin) the Traceability Certificate of Compliance shall also include information verifying that the specific lot of material referenced in the TCC complies with the relevant rejection threshold for GMO (...) RTRS Guidance Comments (...) 50 ProTerra V2.9 RTRS V1 ProTerra Guidance (...) content (0.1% or 0.9% depending on the claim made). This information can be in either of the following two forms: a. The TCC shall reference a certificate of analysis, indicating that the GMO content of the ProTerra certified material complies with the relevant threshold. The report will include the unique identifier of the specific certificate of analysis for the test done on that lot of material, the laboratory that conducted the test (the lab must be ProTerra approved), and information as to where that certificate is filed. b. In cases where the ProTerra certified material cannot or has not been tested directly, two items must be included in the TCC: (a) reference to a certificate of analysis, including certificate number, laboratory conducting the test (the lab must be ProTerra approved), and location where the certificate of analysis is filed, indicating that the specific lot of precursor, from which the specific lot of certified material was derived, complied with the relevant threshold; (b) reference to the location of traceability information linking the specific lot of ProTerra certified material to the specific lot of precursor referenced in the certificate of analysis. 16.3 Records of all processes and analyses shall be maintained for a minimum of 5 years, or longer if specified by local regulations. RTRS Guidance Comments (...) If this requirement is first being met during the initial year that ProTerra certification is achieved, the certification body will waive the retroactive aspect of it for the initial years of certification. (...) No corresponding requirement exists in RTRS 51 ProTerra V2.9 RTRS V1 ProTerra Guidance RTRS Guidance Comments (...) Records comprise but are not limited to: a. Cleaning, system purging, segregation, production and manufacturing processes. b. Analyses result reports for assessing specific properties of inputs or outputs. Such records may include but not be limited to: - date of process or analysis; - dates of production; - production line or facilities used; - product lot numbers; - volume and identification of raw material; - ingredient and input suppliers; - volume of product made; - lot number and locality where product was produced. PRINCIPLE 17 - Continuous improvement undertaken 17.1 Certified organizations shall prepare a written plan for a program of continuous improvement the goal of which will be full compliance with all aspects of the ProTerra Standard. Principle 1: Legal Compliance and Good Business Practice 1.3 There is continual improvement with respect to the requirements of this standard. The results of these activities must be documented or otherwise obvious when being viewed or assessed by the certification body and its inspectors. Note: For group certification - continual improvement should be recorded and monitored at the group level. It is recognized that sometimes there may not be improvement for specific This criterion applies equally to all certified continual improvement indicators due to organizations and sub-contractors, circumstances beyond the control of the including Level I, II and III organizations but certificate holder. is applied with reference to the complexity and size of the operation. 17.1.1 Senior management shall sign this plan to indicate their support and approval. 17.1.2 Based on gap analysis of the differences between the certified organization’s current operations (the baseline) and the requirements of the ProTerra Standard, the (...) RTRS and ProTerra generally equivalent. ProTerra is more specific. No corresponding requirement exists in RTRS 1.3.1 A review process is carried out which identifies those social, environmental and agricultural aspects of the operation (on and off farm) where improvement is desirable. At the time of the yearly audit, progress is assessed against the continuous improvement plan and the plan adjusted as necessary in consultation with the certification body. Note: The producer is expected to be aware of the social and environmental context in which he/she is operating and the existing and possible future impacts of the operation. RTRS and ProTerra generally equivalent. ProTerra is more specific with regards to long term plan for continuous improvement. 52 ProTerra V2.9 RTRS V1 ProTerra Guidance RTRS Guidance Comments (...) organization shall prepare a long-term plan of continuous improvement, laying out long-term objectives and clearly defined measurable milestones to be achieved according to a specified timeline, and including yearly targets. 17.1.3 During the year, the certified organization shall systematically execute the plan for continuous improvement and take all necessary action to correct any complaints and anomalies reported at the time of the previous audit. 1.3.2 A number of indicators are selected and a baseline is established to be able to monitor continual improvement on those aspects where desired improvements have been identified. 17.1.4 During the year, the certified organization shall monitor and document progress in correcting any complaints and anomalies reported as part of the previous audit, and in achieving that year’s continuous improvement targets. 1.3.3 The results of monitoring are reviewed and appropriate action is planned and taken when necessary to ensure continual improvement. 17.1.5 Certified organizations shall maintain records of all audits, inspections by thirdparty inspectors, regulators and client quality assurance personnel for a minimum of 5 years, or longer if specified by local regulations. PRINCIPLE 18 - Correct labelling and logo use 18.1 ProTerra certified materials shall be identified using the ProTerra seal, Traceability Certificates of Compliance, or other documentation that can be used to track the product through the supply chain back to the farm level. Note: Producers are free to choose the continual improvement indicators that are relevant to them to demonstrate continual improvement with respect to the requirements of this standard; e.g. Soil carbon content, use of agrochemicals, state of riparian vegetation etc. The baseline year is the year of first certification assessment. RTRS and ProTerra generally equivalent. RTRS and ProTerra generally equivalent. Records of all audits, internal and external, conducted on the facilities, equipment, conveyances, and documents such as quality manuals, written procedures, documentation of non-compliances accidents, complaints and corrective actions (CAR) shall be maintained. RTRS and ProTerra generally equivalent. If authorised and done in compliance with guidelines of the certification body, the ProTerra seal can be used on raw agricultural materials, processed materials and ingredients and on final consumer products. No corresponding requirement exists in RTRS. RTRS does not function as a consumer-facing seal. (...) No Corresponding Principle 53 ProTerra V2.9 RTRS V1 ProTerra Guidance 18.1.1 All retail and non-retail packaging shall bear a lot or production code that allows for traceability back through all links in the chain of custody of the goods involved, back to the field(s) of origin. 18.1.2 All goods shipped in bulk, where packaging or labels are not feasible, shall be duly identified on associated documentation (the Traceability Certificate of Compliance) including a lot or production code that allows for traceability back through all links in the chain of custody of the goods involved, back to the field(s) of origin. Comments (...) Examples are bulk tankers of liquids, ocean-going containers of loose goods, ship holds, etc. 18.1.3 The client shall make claims and shall use the ProTerra seal only in a manner consistent with the actual scope of their ProTerra certification and shall use the ProTerra name and seal only to identify products and programs that have been certified to be in conformance with the ProTerra Standard. 18.1.4 The client shall not make statements or claims regarding its products or its ProTerra certification program that are misleading or unauthorized. The ProTerra name and the ProTerra logo and certification seal shall only be used on documents, brochures, advertising materials, and product labels as allowed in writing by ProTerra. The client agrees to submit all such materials to CERT ID for approval before placing them in use. RTRS Guidance The ProTerra name and/or logo shall not be used in a manner that can be construed to mean that an entire company’s or operation’s activities and products are certified under these programs, unless they are in fact all duly certified. ProTerra and the certification body reserve the right to require additional explanatory statements be used on marketing materials in association with the seal to make this clear. Such marketing materials include but are not limited to websites, brochures, displays, etc., and will be considered by the certification body on a case-by-case basis. 54 ProTerra V2.9 18.2 Use of ProTerra Seal: 18.2.1 Multi-ingredient products containing 100% ProTerra ingredients can place the ProTerra seal on the front panel of the product and state "100% ProTerra Certified." 18.2.2 Multi-ingredient products containing 95% or more ProTerra ingredients can place the ProTerra seal on the front panel of the product and state "ProTerra Certified." 18.2.3 Multi-ingredient products containing more than 70% ProTerra ingredients cannot use the ProTerra seal but can state "Made with ProTerra Certified XXXX," Where XXXX represents the name of the specific ingredient(s) certified. 18.2.4 Multi-ingredient products containing less than 95% ProTerra ingredients can declare these "ProTerra Certified" in the ingredient panel on the back of the package, but cannot use the ProTerra seal. 18.2.5 It is not allowed to use the same ingredient in both certified and non-certified form in any given formulation. RTRS V1 ProTerra Guidance RTRS Guidance Comments No Corresponding Principle No corresponding requirement exists in RTRS. RTRS does not function as a consumer-facing seal.